Four years after the National Payment Systems (NPS) Act came into force in 2021 — ending a long period where telecom giants operated mobile money services in a regulatory grey area — the Bank of Uganda (BoU) has released a comprehensive update on the state of the market as of December 3, 2025.

The latest public notice lists 54 licensed entities, a significant leap from the initial duo of MTN and Airtel. The data paints a picture of a sector that has moved beyond basic mobile money transfers into a stratified ecosystem of switches, card issuers, and specialized aggregators.

Here is what the data reveals about the digital payment landscape in Kampala.

1. The ‘Big Two’ list has broadened

For years, the narrative in Uganda has been a duopoly: MTN Mobile Money and Airtel Mobile Commerce. When the first licenses were issued in 2021, these were the only two entities qualified for the Large Funds Transfer.

However, the 2025 list shows a shift. Wave Transfer Limited, which entered the market via the BoU’s regulatory sandbox in 2021, has graduated to the top tier. Wave now holds the same “Large Funds Transfer” designations as the telcos. Also on the list are Onafriq Limited, Interswitch, and Cellulant. Notably, Chipper Technologies (Chipper Cash) has also secured a position as a Large Funds Transfer operator and a Class A Card Issuer, validating its significant footprint in the cross-border and P2P space.

This signals that the central bank’s sandbox mechanism is functioning as a legitimate pipeline for scaling new entrants to compete with entrenched incumbents.

2. The rise of the “Middle Class” fintechs

Between the massive telcos and the small startups, a robust middle tier has emerged. The licensing framework categorises operators based on transaction value, creating clear tiers:

• Large Funds Transfer: Transaction value exceeding UGX 100bn ($27m) per month.
• Medium Funds Transfer: Between UGX 1bn ($270k) and UGX 100bn ($27m).
• Small Funds Transfer: Below UGX 1bn ($270k).

The list reveals a dense population in the Medium and Small categories. Companies like Micropay, Mcash, and Flutterwave are populating these tiers.

3. Traditional banks are unbundling

One of the most interesting trends in the 2025 data is the presence of traditional commercial banks acquiring distinct e-money licenses.

• Stanbic Bank Uganda, Absa Bank Uganda, Salaam Bank, and Pearl Bank are all listed specifically as e-money issuers.

This suggests a strategic shift where banks are no longer content to simply hold custody of funds for fintechs; they are actively unbundling their operations to compete directly in the agile electronic money space, likely to bypass legacy banking core limitations and offer lighter, faster wallet services.

4. Global giants and infrastructure plays

The list confirms that Uganda is attracting significant global and pan-African infrastructure players who are engaging in “plumbing” rather than just consumer apps.

• Orion Payment Solutions (noted as a Mastercard company) has secured a license for Clearing Systems or Switches.
• Onafriq (formerly MFS Africa) holds a Large Funds Transfer license.
• dLocal, the emerging markets payments unicorn, is licensed for Medium Funds Transfer.

The presence of these entities indicates that the market is deepening. It is no longer just about sending money from Person A to Person B; it is about interoperability, cross-border settlement, and merchant acquiring.

The Cost of Compliance

The Bank of Uganda has made it clear: the door is closed for unlicensed operations. The public notice explicitly warns that operating without a license attracts prison terms or fines, and permanent disqualification from the financial sector.

For new entrants, the barrier to entry is codified. The capital requirements remain a significant filter for startups:

Note: USD conversions are approximate based on 2021 exchange rates cited in historical data.

The Bottom line

The jump to 54 licensees signifies a maturing market. The “move fast and break things” phase has been replaced by a “comply and scale” mandate.

For investors, this list serves as a verified map of the ecosystem. The distinctions between a “Large” operator and a “Small” one are no longer self-reported vanity metrics but legal classifications based on real transaction volumes verified by the central bank.

The presence of Wave alongside MTN and Airtel, and the entry of global aggregators like dLocal and Mastercard, suggests that while the telcos still dominate, the ecosystem is becoming sufficiently complex to support a diverse range of challengers.